To date, Canada has implemented three rounds of retaliatory tariffs at a rate of 25% against certain US origin goods, with a fourth round of retaliatory tariffs pending after a public consultation period closed on April 2, 2025 (“Retaliatory Tariffs“). Canada has also announced several remission order processes which provide relief from the retaliatory tariffs.
The below chart provides a snapshot of the applicable 25% tariffs, available exceptions and the relevant remission processes announced as of the time of publication.
Canadian Retaliatory Tariffs – Snap Shot
| Implementation Date | Effective Rate | Order in Council and Tariff List | Exceptions | Available Avenues for Remission |
| March 4, 2025 Canada imposed 25% tariffs on CAD 30 billion worth of US origin goods ranging from food items like poultry and pasta to spirits and household appliances | 25% | Order in Council Amendment (04-07) List of Tariff Items | In transit to Canada as of March 4, 2025. Goods classified under heading 40.11 of the Customs Tariff. Goods imported to Campobello Island. Poultry and egg products imported under a Supplemental Import Permit. Returning goods. US manufactured goods returning after repair or alteration. Temporary imports of baggage and conveyances. Eligible ships stores. Certain goods classified under certain Chapter 98/99 tariff items. | Blanket Remission (Certain US Origin Goods) and related Customs Notice – Remission from March 4 to October 16, 2025 Finance Canada – Company Specific Remission – Remission length at request of Company |
| March 13, 2025 Canada imposed 25% tariffs on an additional CAD 29.8 billion in US origin goods including steel and aluminum products | 25% | Order in Council Amendment (04-07) List of Tariff Items | In transit to Canada as of March 13, 2025. Goods imported to Campobello Island. Returning goods. US manufactured goods returning after repair or alteration. Certain aluminum and other goods classified under certain Chapter 98/99 tariff items. | Blanket Remission (Certain US Origin Goods) and related Customs Notice – Remission from March 4 to October 16, 2025 Finance Canada – Company Specific Remission – Remission length at request of Company |
| April 9, 2025 Canada imposed 25% tariffs on US origin, non-USMCA/CUSMA qualifying vehicles imported into Canada and non-Canadian and non-Mexican content of USMCA/CUSMA qualifying US origin vehicles | 25% | Order in Council List of Tariff Items | In transit to Canada as of April 9, 2025. Vehicles specifically designed for travelling on snow, golf carts and similar vehicles (goods of Tariff Item No. 8703.10); and motor vehicles with only spark-ignition internal combustion piston engine of a cylinder capacity not exceeding 1,000 cc (goods of Tariff Item No. 8703.21). Certain goods classified under certain Chapter 98/99 tariff items. Temporary importations of foreign motor vehicles. Returning Canadian-registered motor vehicles that are duty-paid. US manufactured motor vehicles repaired or altered across the border. | Blanket Remission (US Autos) and related Customs Notice – Remission from March 4 to October 16, 2025 Finance Canada – Company Specific Remission – Remission length at request of Company |
| Notice of Intent (Proposed) The Department of Finance issued a Notice of Intent to extend the initial 25% retaliatory tariffs to a further CAD 135 billion of Canada-US trade, after a public consultation, which closed on April 2, 2025 | TBD | List of Proposed Tariff Items | TBD | TBD |
Duty Relief Via Established Remission Processes
As outlined above, there are currently two types of remission processes available in respect of the Retaliatory Tariffs:
- An importer-specific remission process administered by Finance Canada, which requires an application by an importer or by another stakeholder regarding specific goods. Remission is granted retrospectively or prospectively only once Finance Canada approves the request (“Remission Requests“).
- An importer-agnostic, good-specific remission process administered by the Canada Border Services Agency (CBSA), which provides for importers to self determine whether US origin goods imported into Canada qualify for remission (“Blanket Remissions“).
While Remission Requests have been in effect since March 4, 2025 (and we write about it here), the Blanket Remissions were announced by Canada the week of April 14 alongside an update that a loan facility for large Canadian businesses – Large Enterprise Tariff Loan facility – is now accepting applications.
Blanket Remission (Certain US Origin Goods)
On April 15, 2025, Canada issued an Order in Council providing for a blanket remission order on US origin goods used in Canadian manufacturing, processing and food and beverage packaging, and for those used to support public health, health care, public safety, and national security objectives.
Remission for the goods noted below only applies if the goods are:
- imported into Canada before October 16, 2025;
- no other claim for relief of the tariff has been granted under the Customs Tariff in respect of the good; and
- the importer makes a claim for remission to the Minister of Public Safety and Emergency Preparedness (the “Minister“) within 2 years after the date of importation.
Accordingly, importers can claim remission of the Retaliatory Tariffs on goods that were imported into Canada before the April 15 announcement.
Manufacturing/Processing and Food Packaging
Remission is granted to Canada’s retaliatory tariffs implemented on March 4, 2025 (United States Surtax Order (2025-1)) and March 13, 2025 (United States Surtax Order (Steel and Aluminum 2025)) in respect of goods imported for use, in Canada, in the manufacture or processing of any good or the packaging of a food product or beverage.
Imports by Public Health, Public Safety and National Security Bodies
Remission is granted to all Canadian retaliatory tariffs currently in force if imported by or on behalf of the following entities:
- a government health research organization or clinical health research organization;
- an organization that produces or stores medical countermeasures, including pharmaceuticals or medical devices;
- the office of a public health official, as defined in subsection C.10.001(1) of the Food and Drug Regulations;
- an organization that provides ambulance or other emergency response services;
- a firefighting service;
- a law enforcement agency;
- a federal or provincial correctional service;
- the Department of National Defence;
- the Canadian Forces; or
- the Canadian Security Intelligence Service.
Remission is also granted to all Canadian retaliatory tariffs currently in force in respect of goods that are imported under the following conditions:
- for use in the provision of medically necessary health care services, including services provided at a hospital, a health care or dental clinic, a medical, dental or diagnostic laboratory, or a long-term care facility; or
- by or on behalf of an entity that provides products or services related to blood, cells, tissues or organs for medically necessary health care, or a federal, provincial, local or Indigenous health authority.
Remission is also granted to the following goods captured in Canada’s March 3 retaliatory tariffs on US origin goods in the Order in Council: specialized infant formulas; nutrition formulas, metabolic products, formulated liquid diet or human milk fortifiers; medical compression garments; and sterile barrier film or pouches for use in medical manufacturing.
The Customs Notice published by the CBSA lacks interpretative detail. In order to rely on the Blanket Remission Order, an importer does not need to file an application with the Minister. The Customs Notice clarifies that an importer self determines the application of the Blanket Remission Order at the time of importation by entering a special authorization code in the Special Authority OIC field on an importer’s Commercial Accounting Declaration. Post-importation corrections or adjustments may be submitted on the CARM Client Portal in order to claim remission retroactively.
Blanket Remission (US Autos)
The Government of Canada announcement also includes a performance-based remission framework for automakers, designed to incentivize continued production and investment in Canada that will allow automakers that continue to manufacture vehicles in Canada to import a certain number of US-assembled, CUSMA-compliant vehicles into Canada. This aims to provide relief from Canada’s United States Surtax Order (Motor Vehicles 2025) that took effect on April 9, 2025. The auto Order in Council lists several requirements for automakers to qualify for this tariff remission order:
- the motor vehicle is imported on or after April 9, 2025 and not later than April 8, 2026;
- the importer makes a claim for remission to the Minister within two (2) years after the date of importation;
- the importer provides the Minister and the Minister of Industry (the “Ministers“) with any information that may be requested by either Minister respecting the importing into Canada and sale in Canada of motor vehicles manufactured in the US;
- the importer also provides those Ministers with any information that may be requested by either Minister respecting the manufacture of motor vehicles in Canada and the goods that originate in Canada that are used in the manufacture of those motor vehicles;
- in the case of an importer that has reduced or paused its manufacturing in Canada because of factory retooling, the importer restarts manufacturing in accordance with the requirements established by the Ministers; and
- no other claim for relief of the surtax has been granted under the Customs Tariff in respect of the motor vehicle.
The Customs Notice clarifies that an importer self determines the application of the Blanket Remission Order at the time of importation by entering a special authorization code in the Special Authority OIC field on an importer’s Commercial Accounting Declaration.
Compliance Considerations re: Blanket Remissions
The relevant Customs Notices confirm that upon a trade compliance verification, the CBSA may assess any undeclared amount of surtax. Accordingly, importers must pay specific attention to whether their imported goods meet the conditions outlined in each Blanket Remission process. Given the slim interpretative analysis provided in each Customs Notice, importers may choose to seek out legal counsel to assess the application of the Blanket Remissions to their goods. An improper self determination by an importer as to whether a Blanket Remission applies may result in liability for unpaid duties (surtax), GST (calculated on the duty-paid value of imported goods) and interest at the specified (higher) rate.
Importers should also be mindful of any additional record keeping required to provide proof that the Blanket Remission properly applied to their imported goods. Note that the necessary records may fall outside the statutory record keeping requirements under the Customs Act and its regulations.
Large Enterprise Tariff Loan Facility
The new Large Enterprise Tariff Loan Facility (LETL), as announced by the Prime Minister in March, is now accepting applicants. This program aims to provide eligible, large businesses with access to liquidity. To qualify for LETL, a business must: have an impact on Canada’s economy as a result of significant operations in Canada or a significant workforce in Canada; have approximately CAD 300 million, or more, in annual Canadian revenue; and require a minimum loan size of CAD 60 million.
